- 50 - Finally, Mr. Katz opined that salaries and bonuses paid to Dennis and Curtis were excessive because the compensation exceeded the 1995 and 1996 median cash compensation for CEO's and COO's included in the ERI data. However, Mr. Katz, like Dr. Lacey, failed to take into account the stock options granted to the CEO's and COO's of the publicly traded companies. See Labelgraphics, Inc. v. Commissioner, supra. Accordingly, we reject Mr. Katz' opinion concerning reasonable compensation paid to Dennis and Curtis for the years at issue. D. Rejection of Expert Witness Opinions Because of fundamental differences in approach among the experts engaged by both parties, the values arrived at in the reports are extremely far apart. Although it is not unusual in valuation cases that two experts reach significantly different conclusions, the reports and testimony of the experts in this case are so dissimilar that the reliability of the experts is brought into question. In this case, the experts reached conclusions that patently favored their respective clients, and their reports were designed to support their conclusions. The purpose of expert testimony is to assist the trier of fact to understand evidence that will determine the fact in issue. See Laureys v. Commissioner, 92 T.C. 101, 127-129 (1989). That purpose is jeopardized when an expert assumes the positionPage: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
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